be heard, both rights enshrined in the Convention on the Rights of the Child. It adds that on November 7, 2017, the request for restoration of ties between the child D and his father was approved and such a plan was again established, a decision that remains in full effect. 28. It maintains that, safeguarding the protection of the family, it has made different proposals for restoring ties between the child and Mr. Córdoba, but it has not been possible reach agreement with the father. It concludes that it did not seek to disregard Mr. Córdoba’s rights; rather, at all times it had respected the principle of the child’s best interest, taking into account that at the time that the child D was found, the factual circumstances had changed and, therefore, were he to be returned, it could lead to irreversible emotional consequences, considering that 13 years had now gone by. III. DETERMINATIONS OF FACT A. Relevant normative framework 29. Article 54 of the Constitution of Paraguay establishes “child protection” as follows: Family, society, and the State have an obligation to guarantee the child’s harmonious integral development, and the full exercise of his or her rights, protecting him or her from abandonment, malnutrition, violence, abuse, trafficking, and exploitation. Anyone may request the competent authority to fulfill these guarantees and to ensure that infractors are punished. In case of conflict, the rights of the child shall take precedence. B. Facts 30. On February 26, 2004, the child D was born, to Mr. Córdoba, an Argentine national,5 and his wife, Mrs. M.R.G.A., a Paraguayan national. 6 D was born in Argentina in Argentina7 . D is an Argentine national8 and was diagnosed at 10 months with epilepsy, requiring neurosurgical check-ups.9 On January 21, 2006, D. was taken from Argentina, without his father’s consent, from the family home in Argentina to Paraguay.10 31. Mr. Córdoba reported the facts to the Fifth Police Station of Moreno, Buenos Aires Province, to which responded Prosecutor’s Office No. 5 of Mercedes, Buenos Aires Province, the body that requested an international search warrant for “child abduction and concealment.”11 Also responding was the First Juvenile Court, Buenos Aires Province, which opened case 6812, “C.G.D.A.Y. S/International Return.”12 On January 25, 2006, Mr. Córdoba filed a request for international return of the child D with the Department of International Judicial Assistance of the Ministry of Foreign Affairs of Argentina, central authority designated for application of Inter-American Convention on the International Return of Children.13 32. On February 26, 2006, the Ministry of Foreign Affairs and Worship of Argentina submitted to the National Secretariat for Children and Adolescents, in its capacity as central authority of Paraguay, a request for return of the child D.14 On April 10, 2006, the National Secretariat for Children and Adolescents of Paraguay filed a petition Annex 1. National Identity Document of Arnaldo Javier Córdoba. Petitioner’s submission of September 12, 2011. Annex 2. “Files a Complaint.” Submission from Arnaldo Córdoba to Senator of the Nation of Argentina Carlos Rossi. Petitioner’s submission of September 12, 2011. 7 Annex 3. Extract of the birth certificate of child D. Petitioner’s submission of September 12, 2011. 8 Annex 4. Motion to Vacate.” Submission signed by the Duty 6 Defender for Children and Adolescents, August 4, 2006. Petitioner’s submission of September 12, 2011. 9 Annex 5. Medical assessment of Posadas National Hospital. Petitioner’s submission of September 12, 2011. 10 Annex 6. “Busca a su hijo que se lo llevó su madre a Paraguay,” [Looking for his Son Taken by His Mother to Paraguay] Diario El Comercial. Petitioner’s submission of September 12, 2011. 11 Annex 2. “Files a Complaint.” Submission of Arnaldo Córdoba to Senator of the Nation of Argentina Carlos Rossi. Petitioner’s submission of September 12, 201. 12 Petitioner’s submission of August 9, 2019. 13 Amicus curiae brief submitted by the Republic of Argentina, dated October 22, 2009. 14 Petitioner’s submission, enlarging on the report and requesting precautionary measures, dated April 18, 2018. 5 6

Select target paragraph3